Document rBQ3NDBXE7dJZMbgpq5Z9qNmq

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 08/05/2021 - 08/05/2021 Announced: No Entry: 11:58 AM (AKT) Exit: 03:30 PM (AKT) RCRA Title 40 - ENVIRONMENTAL PROTECTION AGENCY Company Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) Type of Operation: Size of Facility: Length of Facility at Location: Geographic Coordinates: Mailing address: (Secondary Address) State of Alaska Department of Transportation and Public Facilities (Alaska DOT & PF), Alaska Marine Highway System (AMHS) ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM 3501 TONGASS AVE KETCHIKAN, AK 99901-9101 Alaska marine ferry terminal Approximately 6 acres ADOT&PF has operated the Alaska Marine Highway System at various locations on Tongass Avenue in Ketchikan for at least 30 years. ADOT&PF previously reported that the facility was located at 3501 Tongass Ave from July 2011-August 2012 and reported other addresses as the facility location during other years (see detailed discussion below). 55.356395, -131.69418 Mr. John Falvey, Division Director - PX john.falvey@alaska.gov Transportation & Public Facilities MHD - Operations 7559 N Tongass Hwy, Ketchikan, AK 99901 (City, state, zip code) County: CC: Ms. Katie Taylor, Terminal Manager II katie.taylor@alaska.gov Mr. Edsel Clayton, Occupational Safety and Compliance Officer edsel.clayton@alaska.gov Ketchikan, AK 99901 Facility/Site Identifier: Media Number: NAICS: Facility has not requested a new EPA I.D. for the current location. Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2021.10.21 06:42:34 -08'00' Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Jen Sullivan Jennifer A Sullivan REGION 10 1 of 25 Digitally signed by Jennifer A Sullivan Date: 2021.10.21 08:21:39 -07'00' Sullivan.Jennifer.A@epa.gov (206) 553-6978 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): 08/05/2021 - 08/05/2021 SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273) and used oil management (40 C.F.R. Part 279). The inspection was conducted as part of a Core Program requirement for FY 2021. Attendees Title Lead Inspector Terminal Manager II Occupational Safety and Compliance Officer Assistant Terminal Manager Name Jon Jones Katie Taylor Edsel Clayton Ted Cabot Phone Email (907) 271-6329 Jones.Jon@epa.gov (907) 305-0418 katie.taylor@alaska.gov Present in Opening Conf. Yes Yes Present in Closing Conf. Yes Yes (907) 228-7277 edsel.clayton@alaska.gov No Yes (907) 617-7085 ted.cabpt@alaska.gov Yes Yes Opening Conference EPA Inspector Jon Jones arrived at the Alaska DOT & PF, Alaska Marine Highway System Terminal at 11:58 AM (AKT) on 08/05/2021 for an inspection. I presented my credentials to Ms. Katie Taylor, Terminal Manager and informed her that this was an EPA RCRA inspection. The table above presents all the opening and closing conference inspection participants. During the inspection I looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. I looked for wastes that facility representatives had not yet identified or designated as hazardous. I also observed the facility's universal waste and used oil management. Only those areas in which I observed areas of concern or noted other pertinent issues are discussed in this inspection report. Both Ms. Taylor and Mr. Cabot told me that Mr. Kevin Larson, Warehouseman, (907-228-6822, kevin.larson@alaska.gov) takes waste from the vessels after they arrive to the terminal and places it in a HazMat storage shed that the facility refers to as a hazardous waste Connex. According to facility representatives, when the Connex gets full, the contents are shipped south by Alaska Marine Lines. I was also told that Mr. Edsel Clayton, Occupational Health and Safety Officer, manages the disposal of the waste in the Connex. During the opening conference, I spoke with the facility representatives about the EPA I.D. number that the facility was using for its current location at 3501 Tongass Avenue. I explained to Ms. Taylor and Mr. Cabot that 2 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): 08/05/2021 - 08/05/2021 EPA I.D. numbers were site specific and when a facility moves to a different site location that facility is required to get a new EPA I.D. number for the new site. I explained that according to the information we had in our database, the facility most recently notified EPA on 8/4/2012 that the facility address associated with I.D. AKD983069444 was 3718 Tongass Avenue. I told them that on 7/5/2011 their facility had provided information to EPA that the address to which that EPA I.D. number was assigned was 3501 Tongass Avenue, and on 1/26/2009, ADOT&PF had provided information to EPA that the address associated with the EPA I.D. was 3723 Tongass Avenue. From 3/22/1991 until 1/26/2009, ADOT&PF had identified the address as 3718 Tongass Ave. Ms. Taylor and Mr. Cabot both stated that the 3718 and 3723 Tongass Avenue locations currently belonged to VIGOR Shipyard and confirmed that 3501 Tongass Avenue is the current address of the ADOT&PF facility. I explained that the facility would need to resolve the EPA I.D. issue. I was accompanied during the inspection by several different facility representatives. At the point when I inspected the hazardous waste Connex, I was accompanied by Mr. Larson. While I was inspecting the hazardous waste Connex it was raining heavily and the hazardous waste Connex did not have adequate room for anyone to enter, so Mr. Larson returned to the Terminal building while I took notes and photographs. At the point when I inspected the facility's little gray warehouse, a storage location for equipment and parts, I was accompanied by Ms. Taylor. While inspecting that area we were joined by Mr. Edsel Clayton, Occupational Health and Safety Officer. Facility/Site Description The Alaska Department of Transportation& Public Facilities (Alaska DOT & PF), Alaska Marine Highway System (AMHS) Ferry Terminal has been at its present location for more than 20 years. The facility is a Marine Ferry Terminal operated and maintained by the State of Alaska. Facility Info Safety Training No Provided to Inspector(s)? What type of generator facility verified as? At the time of the inspection, the facility was generating hazardous waste in Very Small Quantity Generator (VSQG) quantities. Operating Hours Dependent on vessel scheduling, but generally between 7:00 a.m. and 4:00 p.m. Weather Conditions Overcast and rainy Number of employees 5 What type of generator facility notified? The facility has not notified as a generator of hazardous waste at this location. 3 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): 08/05/2021 - 08/05/2021 Process Description During the opening conference, Ms. Taylor and Mr. Cabot described the following wastes generated at the 3501 Tongass Ave. location: Waste lead-acid batteries from defibrillator. Waste NiCad batteries from hand-held communication radios. Waste fluorescent lamps managed through an on-site drum-top crusher. According to facility representatives, all the AMHS ferry vessels dispose of their waste at the Ketchikan Terminal. Wastes generated on the vessels and turned in at the Terminal include the following: Used oil Dirty bilge water Paints and coatings Waste fluorescent lamps Building(s) Building/Area/Sub-area AMHS Terminal Terminal Office Hazardous waste Connex Lamp crushing side Paint and chemical side Little gray warehouse Just outside along fence Southside interior Process Description Used to store various wastes from vessels and terminal. Storage of the lamp crusher and waste lamps. As well as flammable waste. Storage of parts and equipment Area of Concern Yes Yes Yes Yes Yes Yes Yes Yes SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: AMHS Terminal/Terminal Office Observation #: JJ1-OB-009 Contains CBI: No Date: 10/13/2021 While I was in the Terminal Office, I saw two batteries that, according to facility representatives, were waste batteries. One was a lead-acid battery that came out of a defibrillator and was dated 4/22/2020. The second battery was a Ni-Cad battery that came out of a hand-held radio and was dated 12/28/2020. 4 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): 08/05/2021 - 08/05/2021 Building: Hazardous waste Connex/Lamp crushing side Observation #: JJ1-OB-002 Contains CBI: No Date: 08/05/2021 At the time of the inspection, while inside the hazardous waste Connex, I saw multiple cardboard containers that held four-foot fluorescent lamps, and I saw some loose four-foot fluorescent lamps. I also saw a drum-top lamp crusher connected to a 55-gallon container. Some cardboard containers that held four-foot fluorescent lamps were labeled with the words, "Dead Bulbs", "Burnout Bulbs", or "Bad". Most of the lamps also had darkened ends which are indicative of waste fluorescent lamps. I asked Mr. Clayton, after he arrived onsite, about the fluorescent lamps and he stated that they were waste lamps. According to Mr. Clayton the fluorescent lamps are generated on vessels and in the Terminal. He stated that the lamps are placed inside the hazardous waste Connex and then they are crushed with the drum-top crusher. While in the hazardous waste Connex I saw the following waste lamps: 16 unpackaged, four-foot waste lamps 19 boxes of four-foot waste lamps - 6 of the boxes were not closed and all 19 boxes were improperly labeled. Photo(s) 1. Observation_Image-2021080513282128211019305.jpg 2. Observation_Image-2021080513283628361394796.jpg 3. Observation_Image-2021080513285328531639001.jpg 4. Observation_Image-2021080513302730271400335.jpg 5. Observation_Image-2021080513304830481295532.jpg 6. Observation_Image-2021080513311231121279828.jpg 7. Observation_Image-2021080513441844181745394.jpg 8. Observation_Image-202108051344464446788543.jpg Building: Hazardous waste Connex/Lamp crushing side Observation #: JJ1-OB-003 Contains CBI: No Date: 08/05/2021 While in the hazardous waste Connex I saw various one-gallon containers of waste paint. Six of the one-gallon containers of waste paint were not closed, and the contents had been allowed to dry out. At least some of the labels on the containers indicated their contents were combustible and others identified the contents as stoddard solvent and hazardous substances. At the time of the inspection, it did not appear that the six containers would have been "RCRA-empty" prior to drying out. Photo(s) 1. Observation_Image-2021080513371637161380489.jpg 2. Observation_Image-2021080513375737571134880.jpg 3. Observation_Image-202108051338253825970953.jpg 4. Observation_Image-202108051340024021088208.jpg 5. Observation_Image-2021080513412141211374256.jpg 6. Observation_Image-2021080513422542251523419.jpg 7. Observation_Image-2021080513464946491325342.jpg 8. Observation_Image-2021080513471247121631419.jpg 9. Observation_Image-2021080513473247321308046.jpg 10. Observation_Image-2021080513485048501257507.jpg 11. Observation_Image-2021080513491749171239986.jpg 5 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): 12. Observation_Image-2021080513494849481375434.jpg 13. Observation_Image-2021080513505350531266970.jpg 14. Observation_Image-2021080513511651161224262.jpg 15. Observation_Image-2021080513513451341650061.jpg 16. Observation_Image-2021080513523952391208949.jpg 17. Observation_Image-202108051353045341088047.jpg 18. Observation_Image-2021080513532753271198498.jpg 08/05/2021 - 08/05/2021 Building: Hazardous waste Connex/Lamp crushing side Observation #: JJ1-OB-007 Contains CBI: No Date: 08/05/2021 While inspecting the hazardous waste Connex I saw that the facility had a drum-top bulb eater (Lamp crusher). After Mr. Clayton arrived, he told me that ADOT&PF crushes the waste fluorescent lamps and disposes of the crushed lamps. According to the copies of hazardous waste manifests that were provided by Mr. Clayton to me following the inspection, the crushed waste fluorescent lamps were being managed as hazardous waste to which ADOT&PF assigns the waste code for mercury. Mr. Clayton did not provide any information to indicate that the facility was operating in accordance with the small or large quantity generator conditions in order to treat hazardous waste in its own containers. Building: Hazardous waste Connex/Lamp crushing side Observation #: JJ1-OB-008 Contains CBI: No Date: 08/05/2021 While inspecting the hazardous waste Connex, I saw that the facility had, according to Mr. Clayton, a large number of expired flares and rockets used for maritime emergencies. Mr. Clayton told me the facility used to give the expired flares and rockets away to a local maritime organization that used them for training purposes. He said that organization has since gone to another type of training and no longer accepts these expired flares. He told me they were in the process of trying to figure out what to do with them. Building: Hazardous waste Connex/Paint and chemical side Contains CBI: No Observation #: JJ1-OB-001 Date: 08/05/2021 At the time of the inspection, I saw a 5-gallon container and a 55-gallon container located in the paint and chemical side of the hazardous waste Connex. Mr. Larson told me that he had no idea what the 5-gallon container held. The 5-gallon container was labeled as calcium hypochlorite capsules. The 55-gallon container was empty. After Mr. Clayton arrived, he verified that the 5-gallon container held calcium hypochlorite capsules and that the 55-gallon container was empty. Photo(s) 1. Observation_Image-2021080513125312531467981.jpg 2. Observation_Image-202108051313071371408393.jpg 3. Observation_Image-2021080513132313231545090.jpg 6 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): 08/05/2021 - 08/05/2021 Building: Little gray warehouse/Just outside along fence Observation #: JJ1-OB-004 Contains CBI: No Date: 08/05/2021 While inspecting the area just outside the warehouse I saw a 55-gallon container that was labeled with the words, "Waste Oil." I pushed on the container and it felt full. Mr. Clayton verified that the container held used oil. Photo(s) 1. Observation_Image-202108051418001801891927.jpg 2. Observation_Image-2021080514181618161678526.jpg 3. Observation_Image-2021080514184218421622442.jpg Building: Little gray warehouse/Just outside along fence Observation #: JJ1-OB-005 Contains CBI: No Date: 08/05/2021 While still inspecting the area just outside the warehouse I saw another 55-gallon container that was labeled with the words, "Water?" I pushed on the container and it felt full. The container also had a DOT Class 9 label stuck to the side of it. The question mark on the container indicates a waste determination is required. Photo(s) 1. Observation_Image-2021080514202120211855149.jpg 2. Observation_Image-2021080514203620361656723.jpg Building: Little gray warehouse/Southside interior Observation #: JJ1-OB-006 Contains CBI: No Date: 08/05/2021 While inspecting the inside of the warehouse, I saw a 55-gallon container, that according to Messrs. Clayton and Larson held used oil. At the time of the inspection, the container was half full of used oil and was not labeled. Photo(s) 1. Observation_Image-2021080514362236221351735.jpg 2. Observation_Image-2021080514363636361320386.jpg 3. Observation_Image-2021080514364936491469813.jpg Records Review Record: Shipping Documents/Tolling agreements Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: No Reviewed Date: 08/05/2021 According to Mr. Clayton, all the paperwork associated with the management of waste was being kept in an offsite location. Mr. Clayton agreed to email copies of manifests and other disposal paperwork. The information was received following the inspection and is included with the report. 7 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): 08/05/2021 - 08/05/2021 SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: AMHS Terminal JJ1-OB-009 Area: Terminal Office Sub-area: The facility failed to meet the universal waste labeling requirements with regard to the waste batteries. Citations: Sections: Building: Hazardous waste Connex JJ1-OB-002 Area: Lamp crushing side Citations: At the time of the inspection, I saw: 16 loose and unpackaged waste fluorescent lamps. 19 boxes of waste fluorescent lamps - 6 of the boxes were not closed, and all 19 boxes were improperly labeled. JJ1-OB-003 Six one-gallon paint containers were not closed, and the contents were allowed to dry out. The containers would not have been "RCRA - empty" prior to drying and at least some of the container labels identified the container contents as combustible. Citations: Sub-area: Sections: Sections: JJ1-OB-007 The facility failed to meet the universal waste labeling requirements with regard to the waste lamps prior to crushing. Citations: Sections: JJ1-OB-008 8 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): The facility has failed to make a waste determination for the expired flares and rockets. Citations: Building: Hazardous waste Connex JJ1-OB-001 Area: Paint and chemical side The facility has failed to make a waste determination for the five-gallon container of calcium hypochlorite capsules. Citations: Building: Little gray warehouse JJ1-OB-006 Area: Southside interior Citations: 55-gallon container of used oil. Container is half full and not labeled with the words, "Used Oil." Building: Little gray warehouse JJ1-OB-004 Area: Just outside along fence 55-gallon container of used oil that was labeled with the words "Waste Oil." Citations: JJ1-OB-005 The facility has failed to make a waste determination for the 55-gallon container labeled "Water?" Citations: SECTION IV - FOLLOW UP N/A 08/05/2021 - 08/05/2021 Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sections: 9 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): 08/05/2021 - 08/05/2021 Closing Conference I thanked everyone for their time and cooperation during the inspection and began a review of the areas of concern that I observed during my walk-through inspection while at the facility. I noted that the areas of concern identified are not formal findings of violation. I then explained the follow-up process that would take place after the inspection. Following the Inspection Following the inspection, I phoned Mr. Clayton and sent him a follow-up email requesting additional information about waste management by the facility . In the email, I specifically requested an inventory of the wastes in the hazardous waste Connex and applicable Safety Data Sheets, as well as copies of disposal paperwork and any weekly inspection documentation. Mr. Clayton responded in emails dated 8/31/21 and 9/1/21 with the requested information which is included with this report. He also provided the copies of manifests and other disposal paperwork that I had requested during the inspection. SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VI - LIST OF APPENDICES Photo Log 10 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 12:15 PM (AKT) Jon Jones Terminal Office No CBI No PII View of waste lead-acid battery from defibrillator. [Title] 08/05/2021 12:17 PM (AKT) Jon Jones Terminal Office No CBI No PII View of the date the waste lead-acid battery became a waste. [Title] 08/05/2021 12:33 PM (AKT) Jon Jones Terminal Office No CBI No PII View of waste NiCad battery from handheld radio. 08/05/2021 - 08/05/2021 11 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 01:54 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII View of waste flares and rockets in the hazardous waste Connex. [Title] 08/05/2021 01:55 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of waste flares and rockets in the hazardous waste Connex. [Title] 08/05/2021 01:28 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII View of boxes containing waste fluorescent lamps. 08/05/2021 - 08/05/2021 12 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 01:28 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of boxes containing waste fluorescent lamps. [Title] 08/05/2021 01:28 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of boxes containing waste fluorescent lamps. [Title] 08/05/2021 01:30 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of boxes containing waste fluorescent lamps and loose waste fluorescent lamps adjacent to the "Bulb Eater." 08/05/2021 - 08/05/2021 13 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 01:30 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of boxes containing waste fluorescent lamps and loose waste fluorescent lamps adjacent to the "Bulb Eater." [Title] 08/05/2021 01:31 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII View of loose waste fluorescent lamps. [Title] 08/05/2021 01:37 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII View of various one-gallon containers of waste paint that has been allowed to dry out. 08/05/2021 - 08/05/2021 14 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 01:37 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII View of the label on the container. [Title] 08/05/2021 01:38 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of the container label. [Title] 08/05/2021 01:40 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of the container label. 08/05/2021 - 08/05/2021 15 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 01:41 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of the container label. [Title] 08/05/2021 01:42 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of a one-gallon container of waste paint that has been allowed to dry out. [Title] 08/05/2021 01:44 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of waste fluorescent lamps. 08/05/2021 - 08/05/2021 16 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 01:44 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of loose waste fluorescent lamps. [Title] 08/05/2021 01:46 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of a one-gallon container of waste paint that has been allowed to dry out. [Title] 08/05/2021 01:47 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII A view of the label on the paint can, seen in the previous photo. 08/05/2021 - 08/05/2021 17 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 01:47 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII A view of the contents of the container seen in the previous two photos. [Title] 08/05/2021 01:48 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of the labeling on the containers of dried paint. [Title] 08/05/2021 01:49 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of the labeling on the containers of dried paint. 08/05/2021 - 08/05/2021 18 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 01:49 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII A view of the contents of the container seen in the previous two photos. [Title] 08/05/2021 01:50 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII Another view of a one-gallon container of waste paint that has been allowed to dry out. [Title] 08/05/2021 01:51 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII A view of the contents inside the container seen in the previous photo. 08/05/2021 - 08/05/2021 19 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 01:51 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII A view of the label on the can seen in the previous photo. [Title] 08/05/2021 01:52 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII A view of the label on another can of dried out paint. [Title] 08/05/2021 01:53 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII A close-up view of the labeling on the container seen in the previous photo. 08/05/2021 - 08/05/2021 20 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 01:53 PM (AKT) Jon Jones Hazardous waste Connex/Lamp crushing side No CBI No PII A view of the contents inside of the container seen in the previous two photos. [Title] 08/05/2021 01:12 PM (AKT) Jon Jones Hazardous waste Connex/Paint and chemical side No CBI No PII View of the Calcium Hypochlorite tablet container. [Title] 08/05/2021 01:13 PM (AKT) Jon Jones Hazardous waste Connex/Paint and chemical side No CBI No PII A close-up view of the Calcium Hypochlorite tablet container. 08/05/2021 - 08/05/2021 21 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 01:13 PM (AKT) Jon Jones Hazardous waste Connex/Paint and chemical side No CBI No PII Another close-up view of the Calcium Hypochlorite tablet container. [Title] 08/05/2021 02:18 PM (AKT) Jon Jones Little gray warehouse/Just outside along fence No CBI No PII View of 55-gallon container labeled as waste oil. [Title] 08/05/2021 02:18 PM (AKT) Jon Jones Little gray warehouse/Just outside along fence No CBI No PII Close-up view of the container showing the words, "Waste Oil." 08/05/2021 - 08/05/2021 22 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 02:18 PM (AKT) Jon Jones Little gray warehouse/Just outside along fence No CBI No PII Another view of the same container with the words "Waste Oil.". [Title] 08/05/2021 02:20 PM (AKT) Jon Jones Little gray warehouse/Just outside along fence No CBI No PII View of the 55-gallon container labeled "Water?" [Title] 08/05/2021 02:20 PM (AKT) Jon Jones Little gray warehouse/Just outside along fence No CBI No PII Another view of the 55-gallon container labeled "Water." 08/05/2021 - 08/05/2021 23 of 25 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): [Title] 08/05/2021 02:36 PM (AKT) Jon Jones Little gray warehouse/Southside interior No CBI No PII View of a 55-gallon container that is half-full of used oil and not labeled. 08/05/2021 - 08/05/2021 [Title] 08/05/2021 02:36 PM (AKT) Jon Jones Little gray warehouse/Southside interior No CBI No PII Another view of the same 55-gallon container, seen in the previous photo, that is half-full of used oil and not labeled. [Title] 08/05/2021 02:36 PM (AKT) Jon Jones Little gray warehouse/Southside interior No CBI No PII Another view of the same 55-gallon container, seen in the previous photo, that is half-full of used oil and not labeled. Document Log Document Type Communications Document Name Contains Contains Uploaded By CBI PII 8.31.21 Email from Ed.pdf No No Jon Jones 24 of 25 Date Received 10/07/2021 ALASKA DOT & PF, ALASKA MARINE HWY SYSTEM Inspection Date(s): 08/05/2021 - 08/05/2021 Communications 9.1.21 Email from Ed.pdf No No Jon Jones Manifests Uniform Hazardous Waste Manifest No No Jon Jones 2018.pdf Manifests Uniform Hazardous Waste Manifest No No Jon Jones 2021.pdf Other - Safety Data Comet 250 line-throwing-rocket-65- No No Jon Jones Sheet 6254-v3-1-1-1-5-sep-2016-us- english-ghs-19-oct-2017-ffx.pdf Other - Safety Data Ikaros Parachute Rocket, Red.pdf No No Jon Jones Sheet Other - Safety Data Ikaros replacement rocket sds.pdf No No Jon Jones Sheet Other - Safety Data Sheet Interlac 665 Base Ultra Deep CLA044-B5.pdf No No Jon Jones Other - Safety Data Interlac 665 Ensign Red CLB295- No No Jon Jones Sheet W2.pdf Other - Safety Data Interlac 665 Signal Green - CLL549- No No Jon Jones Sheet X3.pdf Other - Safety Data Interlac 665 White - CLB000-Q4.pdf No No Jon Jones Sheet Other - Safety Data Sheet PAINSW~1.PDF No No Jon Jones Other - Safety Data POR-15 Rust Preventive Coating- No No Jon Jones Sheet Gray.pdf Other - Safety Data red-parachute-rocket-65-6261-v3-1- No No Jon Jones Sheet 1-1-5-sep-2016-us-english-ghs-19- oct-2017-ffx (1).pdf Inspection Reports Field_Notes_AKD983069444v1.0.pdf No No Jon Jones 10/07/2021 10/07/2021 10/07/2021 10/07/2021 10/07/2021 10/07/2021 10/07/2021 10/07/2021 10/07/2021 10/07/2021 10/07/2021 10/07/2021 10/07/2021 10/07/2021 25 of 25